Who does the United States Exchange Tax Information With?

Tax Information Exchange Agreements: The TIEA is equivalent to the little brother or sister of a DTA (Double Tax Agreement). Generally, when the United States wants to enter into a tax agreement with another country, but the traditional tax treaty is not proper, it instead enters into a TIEA or Tax Information Exchange Agreement.

The traditional tax treaty may not be proper, because of the disparate income laws and regulations of the different countries. Instead of double-tax agreement, which is designed to limit and define certain types of tax laws between the countries, the goal of the TIEA is to facilitate the exchange of tax information and to avoid offshore tax evasion and fraud.

It increases the ability of theIRSto enforce U.S. tax law, fines, andpenalties.

What is a TIEA?

The TIEA is used to exchange tax information between different countries.

As provided by the OECD (Organization for Economic Co-operation and Development):

“The purpose of this Agreement” is to promote international co-operation in tax matters through exchange of information. It was developed by the OECD Global Forum Working Group on Effective Exchange of Information.

The Agreement grew out of the work undertaken by the OECD to address harmful tax practices.

The lack of effective exchange of information is one of the key criteria in determining harmful tax practices. The Agreement represents the standard of effective exchange of information for the purposes of the OECD’s initiative on harmful tax practices.

This Agreement, which was released in April 2002, is not a binding instrument but contains two models for bilateral agreements. A large number of bilateral agreements have been based on this Agreement (see below).”

U.S. Taxpayers at Risk

The reason the TIEA puts taxpayers at risk, is because even in foreign countries that may not have entered into a Double-Tax Treaty or FATCA Agreement, financial information is still being exchanged.

If a Taxpayer has not properly reported their foreign income, and/or properly submitted their FBAR and FATCA Reporting – they may become subject to the Internal Revenue Service offshore fines and penalties.

Sample Tax Information Exchange Agreement Language

Here is sample language from a TIEA between the U.S. and Cayman Islands:

“Whereas the Government of the United States of America and the Government of the Cayman Islands desire to increase international tax transparency and improve access to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) having a Reporting Entity resident for tax purposes in the Cayman Islands operate through the automatic exchange of annual country-by-country reports (“CbC Reports”) by the Competent Authority of the Cayman Islands (“Cayman Islands Competent Authority”) with the Competent Authority of the United States of America (the “United States Competent Authority”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate.

United States TIEA and DTA List

Bermuda

TIEA CAA – pdf (116 KB)

12/7/2017

12/7/2017

Brazil

TIEA CAA – pdf (119 KB)

7/20/2017

7/20/2017

Bulgaria6

DTC CAA

In Negotiations

In Negotiations

Canada

DTC CAA – pdf (120 KB)

6/7/2017

6/7/2017

Cayman Islands

TIEA CAA – pdf (295 KB)

3/8/2018

3/8/2018

Colombia

TIEA CAA – pdf (117 KB)

8/30/2017

8/30/2017

Croatia

MAC CAA – pdf (135 KB)

7/10/2018

7/10/2018

Curacao

TIEA CAA

In Negotiations

In Negotiations

Cyprus

DTC CAA

In Negotiations

In Negotiations

Czech Republic

DTC CAA – pdf (118 KB)

9/28/2017

10/25/2017

Denmark

DTC CAA – pdf (129 KB)

6/21/2017

6/21/2017

Estonia

DTC CAA – pdf (349 KB)

7/26/2017

4/25/2018

Finland

DTC CAA – pdf (289 KB)

9/27/2017

9/27/2017

France1 – 4 – 9

DTC CAA

In Negotiations

In Negotiations

Germany3 _ 5 – 8

DTC CAA

In Negotiations

In Negotiations

Gibraltar

TIEA CAA – pdf (296 KB)

12/18/2018

12/18/2018

Greece

DTC CAA – pdf (325 KB)

9/27/2017

5/21/2018

Guernsey

TIEA CAA – pdf (130 KB)

6/22/2017

12/19/2017

Hungary

DTC IGA – pdf (273 KB)

DTC CAA – pdf (302 KB)

10/25/2018

12/6/2018

12/21/2018

12/21/2018

Iceland

DTC CAA – pdf (117 KB)

5/5/2017

5/5/2017

India7

DTC-IGA

DTC-CAA

3/27/2019

4/09/2019

4/29/2019

4/29/2019

Indonesia2

DTC CAA – pdf (114 KB)

6/13/2018

6/13/2018

Ireland

DTC CAA – pdf (289 KB)

6/15/2017

6/15/2017

Isle of Man

TIEA CAA – pdf (290 KB)

7/20/2017

7/20/2017

Israel

DTC CAA

In Negotiations

In Negotiations

Italy

DTC CAA – pdf (118 KB)

9/27/2017

9/27/2017

Jamaica

DTC CAA – pdf (117 KB)

7/20/2017

TBD

Japan

DTC CAA – pdf (118 KB)

10/12/2018

10/12/2018

Jersey

TIEA CAA – pdf (462 KB)

12/7/2017

12/7/2017

Latvia

DTC CAA – pdf (133 KB)

6/21/2017

6/21/2017

Liechtenstein

TIEA CAA – pdf (324 KB)

5/9/2018

12/19/2018

Lithuania

DTC CAA – pdf (492 KB)

8/30/2017

8/30/2017

Luxembourg

DTC CAA – pdf (117 KB)

10/18/2017

10/18/2017

Malta

DTC CAA – pdf (347 KB)

7/20/2017

12/19/2017

Mauritius

TIEA CAA – pdf (117 KB)

4/27/2018

4/27/2018

Mexico

DTC/TIEA CAA – pdf (120 KB)

10/19/2017

10/19/2017

Monaco

TIEA CAA

In Negotiations

In Negotiations

Netherlands

DTC CAA – pdf (168 KB)

4/11/2017

4/11/2017

New Zealand

DTC CAA – pdf (129 KB)

5/11/2017

5/11/2017

Norway

DTC CAA – pdf (134 KB)

4/26/2017

4/26/2017

Poland

DTC CAA – pdf (135 KB)

12/28/2017

12/28/2017

Portugal

DTC CAA – pdf (117 KB)

10/2/2017

10/2/2017

Republic of Korea

DTC CAA – pdf (115 KB)

6/22/2017

6/22/2017

Singapore

TIEA CAA

In Negotiations

In Negotiations

Slovakia

DTC CAA – pdf (118 KB)

6/21/2017

6/21/2017

Slovenia

DTC CAA – pdf (120KB)

6/4/2018

6/4/2018

South Africa

DTC CAA – pdf (119 KB)

5/26/2017

5/26/2017

Spain

DTC CAA – English pdf

12/19/2017

12/19/2017

Sweden

DTC CAA – pdf (121 KB)

9/28/2017

9/28/2017

United kingdom

DTC CAA – pdf (117 KB)

8/16/2017

8/16/2017

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